Air: Part III

Health Risk Assessment Protocol (HRAP)

7-28  Please verify that the equipment identified in HRA Section 1.2 is the selected equipment

7-29  Section 2.1 notes 90% reduction in HAPs by oxidation catalyst (OC). Please provide basis of this assumption.

7-30  Section 2.1 states the facility will only use diesel when natural gas “unavailable”.  As noted above, please define or provide information on when natural gas is “unavailable”.

7-31  HRAP states that diesel use is being proposed up to 60 days / year.  However, subsequent HRA states that diesel will only be fired 720 hours/year or 30 days on page 4 (which represents a decrease from amount stated in HRAP).  However, page 5/Section 2.1 of HRA states that turbines will be permitted for up to 60 days of diesel firing.  Please clarify inconsistent statements.

7-32  Section 3.0, the Lifespan of the facility is identified as 25-30 years and was used to determine exposure scenario for pollutants.  This may understate actual exposure to contaminants if plant operates longer.  That is, this is significantly less than typical “human lifespan” exposure scenario used in most risk assessments. Please provide basis or source of this assumption.

7-33  Section 3.2 states that RIDEM indicated focus of study was to be PAH, PBTs, and metals. Please provide the source of this statement or reference RIDEM correspondence.

7-34     Section 5.2.4 states that no farms in 5 miles.  RIDEM subsequent comments dispute this statement.  The Sensitive Receptor List included in the HRA Table 4 was the same list as provided in HRAP.  RIDEM’s comments indicated that some farms observed during a cursory review were missing from list.  However, no receptors were added to HRA list from original HRAP.  Please provide rationale for no additional receptors being added to list when RIDEM states that farms can be seen in a “cursory review”.

7-35  Cover letter indicates that RIDEM conditionally approved Air Dispersion Modeling Protocol within July 27, 2015 correspondence. Please provide a copy of this letter, if available.

7-36     Cover letter indicates that RIDEM’s Guidelines for Assessing Health Risk from Proposed Air Pollution Sources document was finalized October 21, 2015 and notes that a January 5, 2016 telephone call from RIDEM’s Mr. Doug McVay verified that the Health Risk Assessment Protocol was approved based on revised Guidelines document. Please provide any documentation and/or correspondence indicating that the Guidelines document has been formally approved/issued by RIDEM, in addition to a published version of the Guidelines.  Further, please provide any written correspondence from RIDEM which states that the HRAP was approved.

7-37     As stated above, Section 2.0 of HRA states that diesel will only be fired 720 hours/year or 30 days on page 4 (which represents a decrease from amount stated in HRAP).  However, page 5/Section 2.1 states that turbines will be permitted for up to 60 days of diesel firing.  Please clarify inconsistent statements.

7-38     Section 2.0 of HRA narrative states that facility will be major source for CO2, which was not mentioned in Protocol. Please clarify how or why this change from HRAP occurred.

7-39     Please provide additional information regarding the calculation of ammonia emissions contained within Table 3.

7-40     HRAP initially stated one (1) 2MM gallon diesel fixed roof AST will be utilized.  HRA states two (2) 2MM gallon diesel AST.  Please provide TANKS emission calculation output sheets and provide any documentation relating to size, number, and configuration of proposed diesel AST(s).  Please clarify/explain.

7-41     Section 3.1, Sensitive Receptor List included as Table 4 contains same information as in HRAP.  However, RIDEM’s comments indicated that some farms were observed during a cursory review were missing from list.  No receptors were added to this HRA list from HRAP.  Please provide rationale for no additional receptors being added to list when RIDEM states that farms can be seen in a “cursory review”.

7-42  Section 4.1, More recent meteorological data is being used (2010-2014) within HRA rather than what was specified in HRAP (2007-2011).  Please provide any RIDEM/Permitee correspondence relating to this change in model data.